Gilberto Castillo v. the State of Texas

Texas Court of Appeals, 1st District (Houston)·Decided February 5, 2026·No. 01-24-00042-CR·Published

Opinion

Opinion issued February 5, 2026

In The

Court of Appeals

For The

First District of Texas

self-defense as defending against deadly force and erroneously omitted information about the burden of proof in a self-defense instruction.

We affirm the trial court’s judgment as modified.

Background1

Appellant Gilberto Castillo and Imelda Pena had a “long-term dating relationship” that began in September 2019. The police had been called to Pena’s home on prior occasions to assist with a “verbal disturbance” between Castillo and Pena. According to Pena, Castillo, who lived with her and her children, assaulted her on “various occasions.” 2 On the night of October 8, 2022, Pena, her children, and Castillo were planning to watch a movie at Pena’s trailer after dinner. Castillo did not stay to watch the movie. He left Pena’s trailer to go drinking with a cousin instead. According to Pena, when Castillo returned to her trailer in the early morning hours of October 9, Castillo had scrapes on his back, arm, hand, and face. Castillo left the trailer, but he returned the same day before daybreak. According to Pena, when Castillo returned to the trailer the second time, he was mad and still intoxicated.

1 Eight witnesses testified during the guilt-innocence phase of trial. We only address the testimony pertinent to Castillo’s self-defense claim.

2 There was conflicting testimony as to whether Castillo lived fulltime with Pena when the incident occurred. Castillo testified that he was already married when he met Pena and when they began to date, he started “leading two lives.”

Castillo kicked the trailer door open and began hitting Pena in the face with his hands.

Pena’s oldest child, A.P., who referred to Castillo as her stepfather, was in the trailer when the incident occurred. She testified that when Castillo returned to the trailer the first time the morning of October 9, he looked like he had been in a fight. He had blood on his face. Castillo told A.P. and her siblings that he had fought a bear. After everyone went to sleep, Castillo left the trailer again. A.P. woke up later that same morning when she heard Castillo screaming at Pena. Castillo was pulling Pena’s hair, hitting her, and cussing at her in the living room. A.P. threw a picture frame at Castillo to get him to stop. Castillo was trying to drag Pena outside the trailer by her hair. Pena was crying. Castillo pulled Pena through the front door of the trailer and down the steps to his car. According to A.P., Castillo threw Pena into the driver’s seat of his car. Pena crawled into the back seat of the car and opened the door to get out. As she tried to get out of the car, Castillo started to drive off. A.P. testified that Pena got injured because the car door was open when Castillo started driving off.

On October 9, 2022, at approximately 6 a.m., the Dickinson Police Department dispatched officers to a domestic violence call at Pena’s trailer. According to the dispatcher, a fourteen-year-old female caller told the dispatcher that her mother, Pena, was being assaulted by her stepfather, Castillo. By the time

police arrived at the scene, Castillo was gone. One of the responding officers observed Pena’s injuries. Pena’s injuries included road rash to her elbows and ankle, redness around her right eye, and a possible blow to the head or pulled hair. The officer later testified that Castillo struck Pena in the face with his hands, pulled her hair, and pushed her to the ground inside her home. Pena also fell while holding onto an open car door as Castillo tried to drive away, but police could not determine whether Pena’s resulting road rash was the result of accidental or intentional conduct by Castillo.

Later on October 9, Castillo went to the police department to give a statement. He spoke to the same officer who spoke to Pena earlier in the day. Castillo told him he had been assaulted by Pena at approximately 3 a.m. that morning. Although Castillo had injuries to his face and body, the officer did not find Castillo credible. He testified he did not find it likely that a male would sustain injuries of that kind when attacked by a female, and the time frame did not match, given that the disturbance to which police were called was at 6 a.m. Castillo was ultimately charged with “assault causing bodily injury with prior conviction” and “failure to stop and give information.”

Castillo testified that the night before the assault, he went to Pena’s trailer to watch a movie with her and her children. He left and when he returned, Pena began to scratch him. According to Castillo, the trailer door was not locked and he did not

kick it open. He testified that some of his scratches were from an argument with Pena when he left the trailer the first time. When he left the first time, he also fell on the stairs to the trailer injuring his back.

Castillo testified that when he tried to leave the trailer the second time, he and Pena began arguing and she was trying to push him and scratch him again. Castillo tried to get out of the house and Pena ran to his car, telling him he was not leaving and screaming at him. According to Castillo, he grabbed Pena by her arm and got her out of his car so that he could leave. He denied that he dragged Castillo out of the trailer by the hair or that he hit her with his hand. Castillo testified he was “just trying to get away, not hurt her.”

The jury convicted Castillo, and the court imposed a sentence of seven years’ imprisonment. This appeal ensued.

Jury Charge Error

Castillo argues the jury charge contains harmful error because the charge referred to the use of self-defense as defending against deadly force and omitted information about the burden of proof in a self-defense instruction.

Applicable Law

It is the trial court's responsibility to deliver to the jury a written charge “distinctly setting forth the law applicable to the case.” TEX. CODE CRIM. PROC. art 36.14; Arteaga v. State, 521 S.W.3d 329, 334 (Tex. Crim. App. 2017). The purpose

of the charge is “to inform the jury of the applicable law and guide them in its application to the case.” Delgado v. State, 235 S.W.3d 244, 249 (Tex. Crim. App. 2007) (citation omitted). A proper jury charge consists of an abstract statement of the law and the application paragraphs. Alcoser v. State, 596 S.W.3d 320, 332 (Tex. App.—Amarillo 2019) (“[A] jury charge should begin with an abstract paragraph defining the elements of an offense, or defining significant words or phrases, followed by an application paragraph that applies that law to the facts of the particular case.”), rev’d on other grounds, 663 S.W.3d 160 (Tex. Crim. App. 2022). The abstract paragraphs serve as a glossary to help the jury understand the meaning of concepts and terms used in the application paragraphs of the charge. Id. at 328. The application paragraphs apply the “pertinent penal law, abstract definitions, and general legal principles to the particular facts and the indictment allegations.” Vasquez v. State, 389 S.W.3d 361, 366 (Tex. Crim. App. 2012). The charge’s application paragraph, not the abstract portion, authorizes a conviction. Crenshaw v. State, 378 S.W.3d 460, 466 (Tex. Crim. App. 2012).

Standard of Review

When reviewing a challenge to a jury charge, we engage in a two-step analysis. We first consider whether error exists in the charge. Kirsch v. State, 357 S.W.3d 645, 649 (Tex. Crim. App. 2012). If error occurred, we next determine whether sufficient harm resulted from the error requiring reversal. Id.

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